A Technical Analysis of Proposed Section 710

Abrams, Howard

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A Technical Analysis of Proposed Section 710

Howard Abrams

Emory University School of Law

Tax Notes, Vol. 117, p. 961, December 3, 2007
Emory Public Law Research Paper No. 07-25

Abstract:
In general, a partner's distributive share takes its characterization from the activities of the venture. Proposed section 710 will rechararterize as compensation the distributive share of any partner who contributes services to the partnership. It also recharacterizes as a sale certain distributions of property to a service partner. This paper examines proposed section 710 in detail and concludes that it is poorly conceived and inappropriately implemented.

Number of Pages in PDF File: 20

Keywords: K34

JEL Classification: law, tax, partnership tax

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Date posted: November 22, 2007 ; Last revised: June 19, 2012

Suggested Citation

Abrams, Howard E., A Technical Analysis of Proposed Section 710. Tax Notes, Vol. 117, p. 961, December 3, 2007; Emory Public Law Research Paper No. 07-25. Available at SSRN: http://ssrn.com/abstract=1031770

Contact Information

Howard E. Abrams (Contact Author)

Emory University School of Law ( email )

1301 Clifton Road
Atlanta, GA 30322
United States